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The Federal Communications Commission (FCC) has made significant strides in the past year toward the modernization of E-rate, the program that subsidizes broadband connectivity for schools and libraries across the country. In July, the FCC an E-rate Modernization Order, the biggest overhaul of the program since it was created 17 years ago. But those changes, which on improving Wi-Fi access and streamlining data collection, were just the beginning of a broader, ongoing process of updating E-rate to help schools and libraries meet their growing 21st century connectivity needs. The FCC is now weighing new data and input from stakeholders about what additional, long-term changes should be made to the program — including the central question of whether E-rate needs more money to survive.

As part of this process, ������Ƶ’s Open Technology Institute and Education Policy Program submitted with this week, urging the FCC to make more aggressive changes to support investment in scalable fiber infrastructure and ensure that E-rate has long-term financial stability. Our comments respond to specific questions teed up in the Further Notice of Proposed Rulemaking (FNPRM) that the FCC released alongside the July E-rate Order, but they also build upon a series of recommendations that we’ve developed in the past year for how E-rate can support .

One of our central recommendations to the FCC is the creation of a “buildout fund” (or “upgrade fund”) to help schools and libraries cover the significant one-time costs of investing in high-capacity broadband infrastructure. The goal of the buildout fund would be to close the “fiber gap” among schools that currently rely on aging telecommunications and cable infrastructure for Internet access — which, according to , is at least 35 percent of schools and 85 percent of libraries in the United States. There is broad consensus that fiber is the for providing high-speed connectivity to the vast majority of schools and libraries in the United States. As we have , the improvements in Wi-Fi capacity that the FCC pushed in the first phase of E-rate reform will not be effective if more aggressive changes that address underlying infrastructure and connectivity challenges are not made in phase two.

These recommendations are consistent with made by FCC Chairman Tom Wheeler earlier this week at the 2014 Education Technology Summit, where he acknowledged that the FCC must still close gaps in both affordability and access to fiber in order to meet the targets that it set for E-rate in the July Order. “Although the most recent step in E-rate modernization necessarily placed an emphasis on Wi-Fi and broadband within schools and libraries,” the Chairman explained, “we know that we must still address the challenge of improving the broadband infrastructure to the building for many schools and libraries, particularly in rural America.” The Chairman and several other FCC Commissioners — including Jessica Rosenworcel, a long-time E-rate champion — have indicated that they are committed to making further changes so that E-rate is actually able to meet its ambitious targets in the next few years.

Of course, a critical element of achieving these goals is making sure that E-rate has sufficient and predictable funding going forward. The E-rate budget is currently capped at around $2.5 billion per year, despite the fact that the FCC has received requests for double that amount in recent years. So it’s no surprise that the to schools and libraries’ digital infrastructure has been the elephant in the room practically since the moment that President Obama in June 2013. As Cisco emphasizes in its recent FCC , “The evidence is in, and the record is clear: E-rate has been underfunded for many years. Having failed to keep pace year after year, funding has stood – and remains – as a significant barrier to the achievement of the Commission’s E-rate goals.” We believe it’s time for the FCC to do something about the problem. That’s why we also joined a broad coalition of stakeholders — including the American Library Association, EducationSuperHighway, the Leadership Conference on Civil and Human Rights, Microsoft, the National Education Association, and Public Knowledge, to name a few — in a this week calling for “a permanent increase in funding to the E-rate program to allow schools and public libraries to keep pace with the rapidly increasing connectivity demands that they face.”

Having strong, equitable Internet infrastructure in our schools and libraries is an integral part of the continuing push for equity, excellence and innovation in our educational system as a whole. That’s why the FCC must finish the job it started in July 2013 and implement additional changes to E-rate that will provide schools and libraries with the infrastructure and ongoing support they need in the long run.

Read the (pdf) submitted by ������Ƶ’s Open Technology Institute and Education Policy program and learn more about our work on .